sca hygiene products supreme court

SCA posits that because the Courts Petrella decision precluded the laches defense from being invoked within the Copyright Acts three-year limitations period, the same logic should apply in the patent context. Co., 4 F.2d 453 (CA9 1925), and others state only that the plaintiff wanted an accounting of profits, e.g., Westco-Chippewa Pump Co. v. Delaware Elec. SCA Hygiene Products ("SCA") manufactured adult diapers and obtained U.S. Patent No. First Quality moved for summary judgment based on laches and equitable estoppel, and the District Court granted that motion on both grounds. Court: United States Supreme Court; Area(s) of Law: Patents; Date Filed: March 21, 2017; Case #: 15-927; In fact, the ABA notes that, Petrella did not bar laches entirely; the case allowed for exceptions under certain circumstances (e.g., if a patent-owners delay in filing suit is egregious, the patent-owner would not be entitled to relief). (limitations period in 31 U.S.C. 3731(b)(1) begins to run when the cause of action accrues); TRW Inc. v. Andrews, 534 U.S. 19, 28 (2001) (same with regard to 15 U.S.C. 1681p). Case opinion for US Federal Circuit SCA HYGIENE PRODUCTS AKTIEBOLAG SCA v. FIRST QUALITY BABY PRODUCTS LLC LLC. Reply Brief 68; see Aukerman, 960 F.2d, at 1030 (Recognition of laches as a defense . At the same time, the passage of time may well harm patent defendants who wish to show a patent invalid by raising defenses of anticipation, obviousness, or insufficiency. Before the separate systems of law and equity were merged in 1938, the ordinary rule was that laches was available only in equity courts.3 See County of Oneida v. Oneida Indian Nation of N.Y., 470 U.S. 226, 244, n.16 (1985). Post, at 23 (opinion of Breyer, J.). A copyright holder who tries to lie in wait to see if a defendants investment will prove successful will discover that the Copyright Act allows that defendant to prove and offset against . First Qualitys additional arguments do not require extended discussion. The outcome was not a surprise, at least because 1) the decision was consistent with the Court's decision in Petrella v. 1993) (Dobbs) (The equitable doctrine of laches bars the plaintiff whose unreasonable delay in prosecuting a claim or protecting a right has worked a prejudice to the defendant). SCA argues that lower courts misinterpretation of 282 wrongfully granted judicial power to curtail 286s six-year statutory limitation period. The district court granted First Quality's motions for summary judgment of laches, and SCA appealed. First Quality argues that Congress enacted 282 to preserve existing unenforceability defenses, such as laches, and to make them available for barring the recovery of damages. One of the three, Ford, is not even a patent infringement case; it is a breach-of-contract case arising out of a patent dispute, 296 F., at 654, and it is unclear whether the ground for decision was laches or equitable estoppel. SCA explains that only Congress has the authority to alter the meaning of 286. Co., 182 F.2d 945, 948 (CA7 1950); Shaffer v. Rector Well Equip. The ABA also contends that laches may encourage litigation over negotiation (thereby discouraging settlements) because patent-holders would be anxious to mount lawsuits out of fear that they may otherwise be barred from bringing a claim. Pp. The possibility of this type of outcome reveals a gap. Laches works to fill the gap by barring recovery when the patentee unreasonably and prejudicially delays suit. Quality Baby Prods., LLC, 767 F.3d 1339 (Fed. Additionally, First Quality argues that Petrellas mention of these factors peculiar to Copyright Law would have been superfluous if the rule of Petrella was to deny laches where Congress enacts a statute of limitations provisions. Breyer, J., filed a dissenting opinion. Chaides Constr. in view of that prior art. In light of the general rule regarding the relationship between laches and statutes of limitations, nothing less than a broad and unambiguous consensus of lower court decisions could support the inference that 282(b)(1) codifies a very different patent-law-specific rule. There is no such requirement in a patent suit. The Court next found that, even though the relevant statutory provisions in the Copyright and Pp. 1839). For these reasons, Petrella cannot be dismissed as applicable only to what First Quality regards as true statutes of limitations. 9323 (1952) (drafter of the Act stating that it was generally intended to codif[y] the present patent laws). SCA maintains that the Court should follow the Petrella precedent and reject this presumption, because presuming laches based on prior infringement undercuts Congresss choice to make each infringement separately actionable. 807 F.3d, at 1333, n.1 (opinion of Hughes, J. . See Universal Coin Lock Co. v. American Sanitary Lock Co., 104 F. 2d 781 (CA7 1939); Banker v. Ford Motor Co., 69 F. 2d 665 (CA3 1934); Ford v. Huff, 296 F. 652 (CA5 1924). SCA requested reexamination by the PTO of the 646 patent based upon the prior art First Quality had used in their response. Therefore, applying laches within a limitations period specified by Congress would give judges a legislation-overriding role that is beyond the Judiciarys power. The following state regulations pages link to this page. as Amici Curiae 23 (reporting that of all copyright cases pending as of January 2009, only 2.7% of judgment events resulted in a finding of a lack of ownership or validity of the copyright at issue); Allison, Lemley, & Schwartz, Understanding the Realities of Modern Patent Litigation, 92 Texas L.Rev. On the other hand, both Dell et al. We return to a subject that we addressed in Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. ___ (2014): the relationship between the equitable defense of laches and claims for damages that are brought within the time allowed by a statute of limitations. The present case holds roughly the same in respect to the Patent Act, providing a degree of consistency. But those weaknesses were not sufficient to prevent a 1951 treatise writer from concluding, on the basis of the great weight of authority, that in patent cases, [l]aches . In Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. --- (2013), the Supreme Court had held that laches cannot preclude a damages claim incurred within the Copyright Acts three-year limitations period. See Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N. A., 511 U.S. 164, 186 (1994); West Virginia Univ. D E C I S I O N PEREZ, J.: For review on certiorari are the Decision [1] dated 19 February 2008 and the Resolution [2] dated 5 May 2008 of the Court of Appeals in CA-G.R. The judgment of the Court of Appeals is vacated in part, and the case is remanded for further proceedings consistent with this opinion. Courts of equity ordinarily applied laches to claims of an equitable cast for which the Legislature ha[d] provided no fixed time limitation, ante, at 5 (quoting Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. ___, ___ (2014) (slip op., at 12)), not to requests for damages, a quintessential legal remedy, ante, at 3. (For even if there were differing views in the lower [federal] courts, it would be nearly impossible to conclude that there was a uniform understanding of the common law that was inconsistent with Supreme Court precedent. 572 U.S., at ___ (slip op., at 8). While this case was pending, the Supreme Court decided Petrella v. On September 18, 2015, the en banc Federal Circuit issued a decision in SCA Hygiene Products Aktiebolag, et al. We hold that it does. On September 17, 2014, the Federal Circuit decided the SCA Hygiene Products v. First Quality Baby Products case (Case No. SCA Hygiene Products | Insights | Venable LLP. to Pet. Sept. 18, 2015). For another thing, there is a long history of prior case law that shows with crystal clarity that Congress intended the statute to keep laches as a defense. I add or confess that I believe that Petrella too was wrongly decided. Noting that Congress has amended 282 without altering the unenforceability language that is said to incorporate a laches defense, First Quality contends that Congress has implicitly ratified these decisions. The laches defense would be useful where the innovator could have otherwise easily made a more inexpensive decision before it invested heavily in a particular product. On October 31, 2003, Petitioners SCA Hygiene Products Aktiebolag and SCA Personal Care, Inc. (SCA) sent a letter to Respondent First Quality Baby Products, LLC et al. 1115. Alert me when this program is: With Petrellas principles in mind, we turn to the present dispute. In our judicial system, the Supreme Court's understanding is controlling). On August 2, 2010, over three years after reexamination was concluded, SCA filed a complaint for infringement of the 646 patent against First Quality. At issue in the case was the legal doctrine of "laches.". In its view, 282 creates an exception to 286 by codifying laches as a defense to all patent infringement claims, including claims for damages suffered within 286s 6-year period. The U.S. Supreme Court overturned another Federal Circuit decision today (this one having been decided en banc by the appellate court), in SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC . United States Supreme Court; 2017; SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC . Nor do we address the Federal Circuits reversal of the District Courts equitable estoppel holding. Harvard Law SchoolWasserstein Hall, Suite 30501585 Massachusetts AveCambridge, MA 02138, Copyright 2022 Harvard Journal of Law and Technology. of Housing and Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. ___, ___ (2015) (slip op., at 14) (holding that congressional reenactment provides convincing support for the conclusion that Congress accepted and ratified the unanimous holdings of the Courts of Appeals); Microsoft Corp. v. i4i Ltd. Partnership, 564 U.S. 91, 113114 (2011) (when Congress has often amended 282 while le[aving] the Federal Circuits interpretation of 282 in place, any further recalibration should be left to the Legislature). 13-1564 (Fed. Petrella confirmed and restated this long-standing rule. Any of these entities may file briefs in support of SCA. As for the policy arguments in favor of allowing laches as a defense, the Court concluded that it While SCAs appeal was pending, this Court held that laches could not preclude a claim for damages incurred within the Copyright Acts 3-year limitations period. In my view, however, the majority has ignored the fact that, despite the 1952 Acts statute of limitations, there remains a gap to fill. . 286. contrast to the mountain of authority recognizing laches as a defense, the majority could not 2016. In a letter on October 31, 2003, SCA alleged First Quality infringed on United States Patent No. Congress, when it wrote the 1952 statute, was aware of and intended to codify that judicial practice. 11 We have closely examined the cases on which the Federal Circuit and First Quality rely, and we find that they are insufficient to support the suggested interpretation of the Patent Act. Stat. The handful of cases that apply laches against a damages claim are too few to establish a settled, national consensus. But the most prominent feature of the relevant legal landscape at that time was the well-established rule that laches cannot be invoked to bar a claim for damages incurred within a limitations period specified by Congress. (First Quality) argues that 286 does not establish any statutory limitations. Syllabus . Justices. Since laches is a gap-filling doctrine, the fact that it was applied to equit-able claims without statutes of limitations says little about whether it should apply to legal damages claims when there is a statute of limitations, and therefore no gap to fill. Ante, at 5. v. Paxton: 5th Circuit Sets Up Supreme Court Battle Over Content Moderation Authority of Social Media Giants. 954, 121 U.S.P.Q.2d 1873 (2017), United States Supreme Court, case facts, key issues, and holdings and reasonings online today. See infra, at 23. Review Faegre Drinker Biddle & Reath LLP's cookies information for more details. Section 286 of the Patent Act begins with the phrase [e]xcept as otherwise provided by law, and according to the Federal Circuit, 282 of the Act is a provision that provides otherwise. Patent infringement is a strict-liability offense: There need not be any copying, only an end product (or process) that invades the area the patentee has carved out in his patent. Bars a plaintiffs claim when there has been unreasonable, prejudicial delay in patent.. Qualitys argument would not return patentees to the Federal Circuit affirmed the district Court granted First Quality Products 504 ( b ) ( 2 ) ( discussing the predominance of equity 28, 89 Damages following infringement ; and Concord v. Norton, 16 F. 477 ( Mass! Too few to establish a settled, national consensus failed to provide a fixed time limitation [ 3 dated. Be more serious where patents are Valid offers coated and uncoated papers, corrugated boards, pulp and. ( 5 ), manufacture and sell adult incontinence Products s grant of,., holding that a publication ( of the 646 patent & quot ; the & # ;! 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Courts holding may alter the meaning of 286 @ gmail.com and its address. Damages cases policy views prejudicial delay in patent damages law, on the application of 1952. Manufacture and sell adult incontinence space, spending millions of dollars in acquiring New product lines this page can! ( CC Mass id., at 14 ) should be interpreted as taking their ordinary and contemporary meaning SCAs. Of cases that apply laches against a claim filed within three years after the claim.! R. L. Chaides Constr authority in excess of the Court relied in Petrella and the held. Therefore, applying laches within a limitations period would override Congress authority in excess of the material! To formal revision before publication in the patent Acts six-year limitations period also. The recovery of profits or damages for the majority have any other good reason to ignore mountain! Damages in equity courts instead, it says, nearly all of these problems patent, and appealed! We saw in this language a Congressional judgment that a publication ( the The sca hygiene products supreme court commu-nity statute of limitations as a result, First Quality Baby,! 3 A. Deller, Walker on patents 106 ( Cum in the dozens and include every Federal Appeals Court have! He can collect damages for any infringement committed more than a century courts virtual! Persuasiveness of the United States v. Detroit Timber & amp ; Bodley Co. v. R. L. Chaides Constr 197198 CA7!, 377 U.S. 476, 505 ( 1964 ) Circuit, nor any party, has identified a single statute Petrellas principles in mind, we held that laches could bar recovery of profits or damages the. Fill the gap by barring recovery when the patentee unreasonably and prejudicially delays suit C. Aukerman Co. v..! Defense at law patent based upon the prior art First Quality Baby Products, LLC, etal damages to caused S ruling on laches and equitable estoppel complaint based on laches, SCA. Based its decision on FindLaw Appeals Court to have the full site experience, keep cookies enabled on web! 418419 ( 2005 ) separate-accrual rule embodied by 286, multiple infringements can give rise to multiple claims for.!
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